Manufacturing Regulatory Compliance Checklist

Quarterly compliance review the EHS manager and quality manager run together to verify the plant meets OSHA, EPA, FDA/UL, and export-control obligations. Covers QMS, environmental permits, workplace safety, product labeling, and controlled technical data.

5 sections 26 steps Collects data
1

Quality Control Procedures

  1. Reconcile SOPs against the current QMS standard
    • Pull each controlled SOP from the document control system and confirm rev matches the routing/traveler in use on the floor. For ISO 9001 and IATF 16949 shops, verify any clause-driven procedures (8.5 production control, 8.7 nonconforming output) reflect the current revision and that obsolete copies have been pulled from work centers.

  2. Audit raw-material lot and heat traceability
    • Sample five recent work orders and trace lot/heat numbers from receiving through the traveler to finished goods. Common gap: the heat number is captured at receiving but lost at the kitting step, breaking traceability for any aerospace or pressure-vessel work.

  3. Verify gauge and CMM calibration status
    • Run the calibration report from the gauge management system. Red-tag and remove from service any gauge past due — micrometers, calipers, pin gauges, CMM probes, hardness testers. Past-due gauges in service mean every measurement since the prior cal date is suspect.

  4. Refresh operator quality training records
    • Cross-check the training matrix against active ECNs and PFMEA changes from the last quarter. Any operator running an op affected by a process change needs documented re-training acknowledgement before next run.

  5. Review NCR aging and CAR effectiveness
    • Pull the NCR queue from the QMS. Flag any NCR open more than 30 days without disposition and any CAR closed without an effectiveness verification (defect-free run for the agreed cycle count or follow-up audit).

    Collects list
  6. Escalate overdue NCRs to the plant manager
    • Build the escalation list with NCR number, age, owner, and reason for delay. Plant manager assigns a closure date; warehouse confirms segregated parts have not been un-segregated by accident during the delay.

2

Environmental Regulations

  1. Confirm hazardous waste generator status
    • Recalculate monthly RCRA generator status — VSQG, SQG, or LQG — based on the last 12 months of waste accumulation. Crossing into LQG triggers contingency plan, biennial reporting, and personnel training requirements that catch shops by surprise.

  2. Verify Title V or synthetic minor permit limits
    • Pull the rolling 12-month emissions tally for VOC, HAP, NOx, and PM. Compare against the permit cap. Coatings, solvents, and welding emissions are the typical drift sources; an unreported new spray booth is the typical citation.

  3. File the annual TRI Form R if at threshold
    • TRI reporting is due July 1 for the prior calendar year. Manufacture/process threshold is 25,000 lb; otherwise-use threshold is 10,000 lb. Tier II (EPCRA 312) is due March 1 — keep both deadlines on the same compliance calendar.

  4. Audit the SPCC plan and secondary containment
    • Walk every aboveground oil tank, drum storage area, and transformer pad. Confirm secondary containment volume is at least 110% of the largest container, drains are closed, and the SPCC plan reflects current tank inventory. PE recertification is required every five years.

  5. Reconcile e-manifest hazardous waste shipments
    • Download the quarter's e-manifests from RCRAInfo and match each to the on-site accumulation log and TSDF receipt. Any manifest without a corresponding signed Copy 5 within 35 days needs an exception report.

    Collects file
3

Workplace Safety Standards

  1. Post OSHA Form 300A in the break area
    • Form 300A summarizing the prior calendar year must be posted Feb 1 through Apr 30 in a location visible to employees. Establishments with 20+ employees in covered NAICS codes also submit electronically via OSHA ITA by March 2.

  2. Verify LOTO procedures for every energized machine
    • Walk the floor with the equipment list. Each machine with a hazardous energy source needs a written, machine-specific LOTO procedure (29 CFR 1910.147) plus annual periodic inspection by an authorized employee other than the one performing the lockout.

  3. Refresh forklift certifications by equipment type
    • 1910.178 requires equipment-specific evaluation every three years and refresher training after a near-miss, accident, or assignment to a new truck class. An operator certified on counterbalance is not certified to drive a reach truck or order picker.

  4. Audit the SDS binder and HazCom labels
    • Walk the chemical cabinet and the storage shed. Every container needs a GHS-aligned label with pictograms; every chemical on the inventory needs a current SDS within reach of the operators who use it. New chemical introductions over the quarter trigger targeted HazCom training.

  5. Review the OSHA 300 log and near-miss data
    • Calculate quarter-to-date TRIR and DART against the plant target. Pull the top three near-miss categories from the EHS system; if any near-miss pattern matches a prior recordable, escalate to a JSA refresh on that operation.

    Collects number
4

Product Safety and Labeling

  1. Confirm UL, CE, and FCC test reports are current
    • Pull the product certification register. Any product with a BOM change since the last test report needs an engineering review to decide whether re-test, delta evaluation, or supplier substitution coverage applies. Expired UL files block shipment to retail customers.

  2. Verify GHS pictograms on chemical product labels
    • For chemical products shipped downstream, confirm labels carry the correct GHS pictograms, signal word, hazard statements, and precautionary statements matching the SDS Section 2. Mismatch between label and SDS is the most common HazCom citation on outbound product.

  3. Screen the field-complaint log for recall triggers
    • Review CPSC reportable-event criteria against the quarter's field complaints, returns, and warranty claims. A defect that creates substantial product hazard requires a Section 15(b) report within 24 hours of meeting the threshold — not at the end of the quarter.

    Collects list
  4. Execute the product recall communication plan
    • Open the recall playbook: notify counsel, file the CPSC Section 15(b) report, freeze the affected lot in ERP, draft customer and distributor notice, and stand up the return-and-replace process. Same-day floor notification stops further bad units from shipping.

  5. Refresh RoHS, REACH, and Prop 65 declarations
    • For products sold into EU or California, confirm supplier declarations on the BOM still cover RoHS substances, REACH SVHC list (current edition), and Prop 65 listed substances above the safe-harbor level. Update outbound declarations and warning labels where suppliers have changed formulations.

5

Controlled Data and Privacy

  1. Classify drawings against ITAR and EAR
    • For new and revised drawings released in the quarter, run the export classification: ITAR USML category, EAR ECCN, or EAR99. Defense article technical data triggers DDTC registration, deemed-export controls on foreign-national employees, and supply chain flow-down obligations.

  2. Audit access controls on the PLM system
    • Pull the access matrix from SolidWorks PDM, Windchill, Teamcenter, or Arena. Confirm controlled-data folders are walled to authorized US persons; remove access for separated employees; verify any foreign-national engineer has either a deemed-export license or a verified exclusion.

  3. Refresh NDA and IP-handling training
    • Engineering, sales, and customer-program staff retake the customer-NDA training annually. Cover the most common slips: emailing prints to personal accounts, photographing the floor for LinkedIn, and using customer-supplied tooling on a non-authorized job.

  4. Refresh CMRT submissions to OEM customers
    • Conflict Minerals Reporting Template (3TG) requests come through OEM supplier portals on an annual cadence. Pull the latest CMRT from each upstream smelter via the supplier portal, confirm RMI conformance status, and resubmit at the customer's required level (company-wide or product-specific).

  5. Sign off on the quarterly compliance review
    • EHS manager and quality manager jointly sign. Capture the headline finding, narrative on any open items, and supporting evidence package. The signed record is the audit trail for the next ISO surveillance visit and any agency inspection.

    Collects list Collects paragraph Collects file

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Sections 5
Steps 26
Category Manufacturing
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